Since the end of the financial crisis, international groups have been revisiting their corporate and tax structures to adapt to the economy and tax climate. In this context, Luxembourg has maintained attractive measures for holding companies and remains a useful platform for investments, not only because of its tax rules, but also for reasons beyond its tax regime, explains Louis Thomas of KPMG Luxembourg
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default